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Surveyors thinking beyond a standard

I was thinking more on my last post about surveyors incorrectly citing folks for not having eyewash stations in all patient care areas.

As far as surveyors looking for these eyewash units and not quite getting the citation going in the right direction, I think we can say, without much fear of repudiation (or retribution), that every once in a while, surveyors develop their own interpretive algorithm for those instances in which there is no clear cut regulatory guidance.

By the way, the survey results for eyewash station citations that I have seen generally fall under EC.1.10, EP 5 (implementing procedures in response to risk assessment findings).

However, I feel the "most correct" home for this citation would be EC.3.10, EP 9 (implementing emergency procedures for hazardous materials and waste spills or exposures).

I suppose the interest on the part of the surveyor cadre is also derived, at least tangentially, from the pas de deux that The Joint Commission has been engaged in with OSHA.

That said, from an empirical standpoint, when you look at the limited number of education days allotted to Joint Commission surveyors, is it really any wonder that the points get blurred over time?

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